Guidelines for conflicts of interest
Everyone who participates in the processing of applications must follow Forte’s policy and guidelines for conflicts of interest. The guidelines are intended to provide support for members of review groups and external assessors. They were decided on 22 November 2021 and apply until further notice.
1. Starting points
Forte’s mandate is to promote and support basic research and needs-based research into working life, as well as in social and public health sciences. The authority’s central task is to distribute funding for research.
Processing cases involving research funding involves a number of aspects that can affect the outcome of such cases. These include checking formal conditions, a decision to disallow an application, distributing applications to different review panels, a decision to grant or reject an application.
According to the Instrument of Government, chapter 1, section 9, in their activities administrative authorities shall take into account everyone’s equality under the law and shall observe objectivity and impartiality. The confidence of the general public in the authorities’ impartiality depends on there being legal rules that make it possible to disqualify a representative of an authority from participating in the processing of a case.
2. The Administration Act and conflicts of interest
Provisions regarding conflicts of interest may be found in sections 16-18 of the Administration Act (2017:900). In its capacity as an administrative authority, Forte shall comply with these provisions in all case processing. The following is an unofficial translation of these sections.
Sections 16-18 of the Administration Act
A person who, on behalf of an authority, participates in case processing in a way which could influence the authority’s decision on a case has a conflict of interest and is legally disqualified if…
- …he or she or a closely associated person is party to the case or may otherwise be assumed to be affected by the decision to a not insignificant extent,
- …he or she or a closely associated person is or has been a representative of a party to the case or of someone else who may be assumed to be affected by the decision to a not insignificant extent,
- …he or she has participated in the final processing of a case at another authority and as a result of this has already come to a decision on questions that the authority shall decide in its capacity as a superordinate body, or
- …there is some other special circumstance that means that his or her impartiality in the case may be brought into question. If it is evident that the question of impartiality has no significance, the authority can conclude that no conflict of interest exists.
A person who has a conflict of interest may not participate in the processing of the case and must not be present when the case is decided. He or she may however perform such tasks as cannot be performed by anyone else without the case processing being considerably delayed.
A person who is aware of any circumstance that may be considered to disqualify him or her must immediately notify the authority of this.
An authority shall decide on any question of conflict of interest as quickly as possible.
The person concerned in the question of disqualification may only participate in the testing of the question of conflict of interest if this is necessary in order for the authority to be competent to make the decision and no replacement can be brought in without the testing of the question being considerably delayed.
3. Preventing conflict of interest
3.1 Information about a conflict of interest
- Any person who is aware of any circumstance that might mean that he or she has a conflict of interest must immediately inform Forte of this.
- The chairpersons and members of review panels, as well as external reviewers, shall in the first instance provide information about a conflict of interest to the senior research officer at Forte.
3.2 Cases that concern applications for research funding
- All those who participate in the processing of applications for research funding shall provide information about conflicts of interest that affect the application or participating researchers who are named in the application. Also, to the extent that is possible, information should be given about conflicts of interest that affect other persons who, according to the application, shall participate in the research.
- Applications for research funding from members of review panels shall not be considered by the group where the person is a member or the chair. This applies regardless of whether the member is the applicant or a participating researcher who is named in the application.
4. Support for assessing grounds for disqualification
An assessment on whether there are grounds for a conflict of interest must always be made on the basis of the provisions regarding conflicts of interest in the Administration Act. These provisions apply to all persons who participate on Forte’s behalf in the processing of a case, including members of review panels.
It is not a person’s title or job description but acting in the individual case that decides whether the rules are applicable.
In some situations, it is clear that there is a conflict of interest. For example, if a person who is to participate in case processing…
- is party to the case
- is a close associate of a party
- is a deputy of a party
- may otherwise be considered to be affected by the decision to a not
insignificant extent.
Other situations may arise that are less clear or difficult to assess. This applies to what is known as a conflict of interest for reasons of discretion and delicacy, where there is some other circumstance that means that impartiality may be brought into question. Examples of circumstances where a conflict of interest for reasons of discretion and delicacy may exist are close friendship, engagement in a case in such a way as to conflict with the presumptions for an impartial assessment, some form of dependence on the person that the case relates to etc.
It is important that all potential conflicts of interest are handled and decided on the basis of the circumstances of the individual case and that the nature, extent and duration of the circumstances that may be considered to mean disqualification are taken into consideration. There is no clear predetermined right or wrong. Therefore, an early dialogue between members of a review panel and staff at Forte concerning conflict of interests, is important.
4.1 Examples of situations where there is a risk of a conflict of interest
- Dependency of a financial or other nature. An example of this could be situations in which an applicant or participating researcher has an assignment as reviewer of someone who participates in the competence, application, department or subject of the processing.
- Ongoing or recently concluded close collaboration, such as in the form of a teacher or student relationship, supervisor or doctoral student relationship, jointly performed research or joint authorship of books or articles.
- A manager or employee relationship.
- Obvious friendship, animosity or difference of opinion.
- When a person who participates in the case processing in another context has handled questions that concern the case, for example as representative of another authority or organisation.
- When a person who participates in the processing of a case belongs to the same economic entity as an applicant or participant and where direct benefits can also be found for the person participating in the case processing.
5. Handling conflicts of interest
- A person who has a conflict of interest may not be present when the case is decided.
- Situations, both where a conflict of interest is assumed to exist and where a conflict of interest has been considered but is not assumed to exist, shall be documented throughout the handling process.
- If a question of conflict of interest has been raised by an external party, or if the question of conflict of interest affects someone who does not consider that he or she is disqualified, or if in some other way there is divided opinion as to whether a person is disqualified, testing of the question of conflict of interest shall immediately be passed on to the authority for a decision.
- The chairperson of a review panel and research officers at Forte shall regularly discuss topics concerning conflict of interest.
6. More information about conflict of interest in public service
More information on the regulations on conflict of interest can be found in the following report from the Swedish Agency for Public Management: Jäv i offentlig tjänst (statskontoret.se) »
Please note that the report is written in Swedish.